1. Introduction

1.1 Who we are

The website found at https://www.assuraplc.com/ (the “Website”) is provided by Assura plc, a company incorporated and registered in England and Wales with company number 09349441 with its registered office at 3 Barrington Road, Altrincham, WA14 1GY (“Assura”, “us”, “our” or “we”).

1.2 Purpose of this Privacy Policy

We take your privacy very seriously. As such, we ask that you read this Privacy Policy carefully as it contains important information about:

(a) what personal data we may collect from you;
(b) how we will use, store and protect your personal data;
(c) with whom we may share personal data; and
(d) your rights under relevant data protection laws.

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. This Privacy Policy supplements the other notices and is not intended to override them.

2. What personal data we may collect from you

We may collect and process the following personal data about you:

  • Identity and Contact data: name, email address, organisation.
  • Technical data: internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Website.
  • Usage data: information about how you use the Website.

3. How we collect personal data from you

We collect your personal data in the following ways:

  • Directly: contact and identity data is provided by you when you fill in online forms or correspond with us in any way, for example when:
    • subscribing for our email alerts service (the “Alerts Service”) through the Website; or
    • submitting a query to us using the enquiry form on the Website.
  • Automatically: as you browse the Website certain information relating to your browsing patterns and technical data about the equipment you are using to access the Website is automatically collected using cookies and other similar technologies. Please see our Cookie Policy for further information.

4. How we use your personal data

We will use your personal data for the following purposes:

  • if you subscribe to our Alerts Service, we will send email alerts to the email address you provide from time to time;
  • if you submit a query to us through the enquiry form on the Website, we will use the contact details you provide to respond to your query and retain details of your query as per section 6; and
  • as we believe to be necessary or appropriate:
    • in order to comply with a legal obligation. This applies where the processing is necessary for us to comply with the law;
    • to enforce or apply this Privacy Policy; and
    • to protect our legitimate rights, privacy, property or safety, and/or those of a third party and your rights do not override those interests.

5. Lawful basis for processing

We are relying on consent as the lawful basis for our processing of your personal data.

You can withdraw your consent at any time. If you would like to withdraw your consent, please let us know by contacting us using the information in section 14.

6. Retention of your personal data

We will not retain your personal data for longer than is necessary for the purposes for which the personal data is processed. This means that your data will only be retained for as long as it is still required to provide you with services or is necessary for other legal reasons. When calculating the appropriate retention period for your personal data, we consider the nature and sensitivity of the personal data, the purposes for which we are processing the personal data, and any applicable statutory retention periods. Using these criteria, we regularly review the personal data which we hold and the purposes for which it is held and processed.

When we determine that personal data can no longer be retained (or where you request us to delete your data in accordance with your right to do so (please see section 10 below for more information)), we ensure that this personal data is securely deleted or destroyed.

For more details about our retention periods, please contact us using the detail provided in section 14.

7. Accuracy of your personal data

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

8. Security of your personal data

In order to protect your personal data, we have implemented appropriate organisational and technical security measures. These measures include restricting access to your personal data to certain employees only, ensuring our internal IT systems are suitably secure, and implementing procedures to deal with any suspected data breach.

In the unlikely event of a data breach, we will take steps to mitigate any loss or destruction of your personal data and, if required, will notify you and any applicable authority of such a breach.

9. Transfer or access to your personal data by third parties

Transfers to third parties

There will be circumstances in which we need to share your personal data with certain third parties, including third parties located outside of the EEA.

The third parties to which we may transfer your personal data include:

  • Investis Limited (“Investis”) [; and
  • [Investis Corporate Communications PVT. Ltd (“ICCP”)].

Investis is a data processor on our behalf who hosts the Website and administers the Alerts Service. The Website is hosted on servers within the EEA, although Investis may utilise the services of its Indian subsidiary ICCP to manage the Alerts Service which may result in your personal data being accessed or processed outside the EEA.

Investis and ICCP have entered into a data sharing agreement whereby your personal data is transferred under the standard contractual clauses which have been approved by the European Commission as providing the same standard of protection for the personal data being transferred as it would receive within the EEA.

For more information on the safeguards used by Assura when transferring personal data to third parties, please contact us using the information in section 14.

10. Your rights

You have certain rights in relation to the personal data we process and hold about you. These include:

  • Right to rectification: you have the right to require us to correct any inaccuracies in your personal data.
  • Right to erasure: you have the right to require us to delete your personal data, subject to certain legal requirements.
  • Right to restriction of processing: you have the right to require us to restrict the way in which we process your personal data. You may wish to restrict processing if, for example:
    • you contest the accuracy of the personal data and wish to have it corrected;
    • you object to our processing but we are require to retain the personal data for reasons of public interest; or
    • if you would prefer restriction to erasure.
  • Right to data portability: you have the right to obtain from us easily and securely the personal data we hold on you.
  • Right to object to processing: you have the right to require us to stop processing your personal data (other than storing it) should you wish the data to be retained but no longer processed.
  • Right of access: you have the right to request access to personal data that we may process about you.
  • Right to withdraw consent: where our lawful basis for processing your personal data is consent, you have the right at any time to withdraw your consent allowing us to process your personal data.

If you would like to exercise any of the above rights, please:

  • put your request to us in writing using the email address below;
  • include proof of your identity (such as a copy of your driving licence or passport) and address (such as a recent utility or credit card bill); and
  • specify the right you wish to exercise.

Response time

We will respond to requests made by you within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Charge

We will not charge a fee for you to exercise any of the rights listed above. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

11. Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Policy.

12. Third party links

The Website may contain links to and from other applications, plug-ins and websites of other networks, advertisers, and affiliates. If you follow a link to any of these websites, please note that they (and any services that may be accessible through them) have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these apps, websites or services. Please check these policies before you submit any personal data to these websites or use such services.

13. Amendments to this Privacy Policy

No changes to this Privacy Policy are valid or have any effect unless agreed by us in writing. We reserve the right to vary this Privacy Policy from time to time. Our updated terms will be displayed on the Website. It is your responsibility to check this Privacy Policy from time to time to verify such variations.

14. Questions in relation to this Privacy Policy

You should also be aware that you have the right to raise any concerns in relation to how we process your personal data to the Information Commissioner's Office (ICO).

Our full details are:

Full name of legal entity: Assura plc
Name or title of DPO: Orla Ball
Email address: [email protected]
Postal address: 3 Barrington Road, Altrincham, WA14 1GY
Telephone number: 01925 420660